June 11, 2018 DOT Letters of Interpretation for May/June 2018 Issue Available in Reference Gateway

By JHMT StaffJune 11, 2018

The Journal publishes in each issue the PHMSA letters of interpretation of the hazardous materials regulations for the previous applicable months. These letters, in addition to appearing in both the print and digital editions of the publication, are archived in the HazMat Reference Gateway under the pulldown module, US DOT: DOT Letters of Interpretation and are fully searchable. These letters contain links to applicable DOT regulations in the 49 CFR in addition to comments we may have made on the letter.

Only The Journal presents the DOT letters of interpretation with the following:

Emailed notification following the issuance of the Digital Edition of The Journal with a link to a webpage at www.hazmatship.com. This link will take you to a page containing a listing by 49 CFR section number (in ascending order) letters covering the previous months; March, April, and some May letters are presented in this reference.

Links to the applicable 49 CFR sections are provided, in addition to links to comments made by our technical advisers. These comments are notated in the index.

You will also note that we have added originating letters to DOT’s responses so that you will have access to the full context of the questioner’s inquiry.

These web pages are directly accessible in a new section from the pulldown US DOT menu, PHMSA Letters: Indexes by Issue

To view the below index in the Reference Gateway, click here. Login is required. Links to the letters themselves are provided there as well as Reference numbers for each letter. Comments by our Technical Advisors are provided on those marked with a ▶.

Date

Section references

Description

May 2, 2018

§ 107.608

Registration requirements

April 24, 2018

§ 171.25

Transportation of lithium metal batteries by vessel

May 1, 2018

§§ 171.8, 172.102(c)(5), 177.834(a)

The definition of “closed motor vehicle”

April 6, 2018

§§ 171.8, 173.22, 173.120, 173.121, l73.l50(f)

Flammable wastes exempt from EPA’s hazardous waste requirements

May 2, 2018

§§ 171.8, 173.240(c), 178.601(h), 173.159(d)(1)

Bulk and non-bulk packaging definitions as they relate to solid material

May 1, 2018

§ 172.202(a)(7)

Clarification of shipping papers

April 2, 2018

§172.315

Limited quantity markings

March 20, 2018

§§173.134(a)(2), 173.134(b)(6), 173.134

Limited quantity markings

March 12, 2018

§173.159a(c)

Symbols or pictograms for non-spillable batteries

April 2, 2018

§173.185

Lithium battery markings

April 13, 2018

§173.306

Limited quantities of compressed gas

March 6, 2018

§§173.4a, 172.101(c)(11), 173.4a(b)

Shipping samples of hazardous materials

March 20, 2018

§§173.4, 173.4a, 173.27(f)(2), 107.401, 178.602(d), 173.27(c)

Package testing requirements for DOT-approved UN Third Party Certification Agencies

March 6, 2018

§175.10

Carriage of a suitcase containing a lithium ion battery onto an aircraft

April 2, 2018

▶ §178.337-9

Required markings on the inlet and outlet equipment on MC331 CTMVs - Letter 1 of 4

April 2, 2018

▶ §178.337-9

Required markings on the inlet and outlet equipment on MC331 CTMVs - Letter 2 of 4

April 2, 2018

▶ §178.337-9

Required markings on the inlet and outlet equipment on MC331 CTMVs - Letter 3 of 4

April 2, 2018

▶ §178.337-9

Required markings on the inlet and outlet equipment on MC331 CTMVs - Letter 4 of 4